Document wDxOeM83ovKe9XEQ074Nvx4LE

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 April 6, 2023 Department of the Navy NAVFAC MIDLNT PWD New London Environmental Division Box 400 439 Tautog Avenue Room 104 Groton, CT 06349-5400 ATTN: Michael Brown Re: U.S. EPA-Region 1 Inspection Report of Naval Submarine Base New London, February 22-23, 2023 Dear Mr. Brown: In accordance with current policy, I am providing you with a copy of the final inspection report summarizing observations made during the February 22-23, 2023 Compliance Evaluation Inspection (CEI) of your facility. Please note, other than Photographs, the attachments referenced in the report are not included as they are already in your possession. This inspection was conducted under the authority of RCRA. Please contact me at 617-918-1678 or Carew.James@epa.gov if you have any questions. Sincerely, JAMES CAREW CAREW Digitally signed by JAMES Date: 2023.04.06 15:23:16 -04'00' James Carew, Life Scientist EPA Inspector, Waste and Chemical Compliance Section cc: Joseph Schiavone, CT DEEP Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA Compliance Inspection of: Naval Submarine Base New London 1 Crystal Lake Road Groton, CT 06340 February 22-23, 2023 Date of Inspection 4/10/23 ______________ Date Inspection Report Approved _4_/_1_0_/2_3_________ Date Inspection Report Finalized _4_/_1_1_/2_3__________ Date Inspection Report Transmitted to Facility James Carew, Life Scientist Waste and Chemical Compliance Section MARY ODONNELL Date: 2023.04.10 15:31:44 -04'00' Digitally signed by MARY ODONNELL _________________________ Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Date: From: Thru: To: Subject: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA HAZARDOUS WASTE INSPECTION REPORT April 6, 2023 Waste and Chemical Compliance Section Lisa Papetti, Senior Enforcement Coordinator Waste and Chemical Compliance Section RCRA Enforcement File Environmental Protection Agency ("EPA") Resource Conservation and Recovery Act ("RCRA") Inspection of Naval Submarine Base New London I. GENERAL INFORMATION Facility Name: Naval Submarine Base New London (facility or Subase) Facility EPA Identification Number: Type of Inspection (CEI, FCI, CSI, etc.): Name(s) of inspector(s): Date(s) of inspection: CT4170022020 Compliance Evaluation Inspection (CEI) James Carew Drew Meyer 22-23 February 2023 II. SITE INFORMATION Site Name: Complete Street Address: Complete Mailing Address: Naval Submarine Base New London 1 Crystal Lake Road, Groton, CT 06340 Department of the Navy NAVFAC MIDLNT PWD New London Environmental Division Box 400 439 Tautog Avenue Room 104 Groton, CT 06349-5400 ATTN: Michael Brown Contact(s) (Name, Title, Phone Michael Brown, Environmental Division Director; Number, Email) (860) 694-3976; michael.brown13@navy.mil Brian Hendrickson, Hazardous Waste Branch Manager; 860-694-4298; brian.g.hendrickson.civ@us.navy.mil David Carter, Lead Environmental Protection Specialist; 860-694-555; David.w.carter2.civ@us.navy.mil Bernadette Reese, Senior RCRA Program Manager, NAVFAC MIDLANT EV12; 757-341-0408; bernadette.reese@navy.mil Date of latest Notification of Hazardous Waste Activities (per RCRAInfo): Date of first Notification of Hazardous Waste Activities (per RCRAInfo): Date established at present location: NAICS Code: Current Property Owner: CAPT Kenneth Curtin Jr., Commanding Officer (CO) 24 Feb 2022 18 Aug 1980 1868 928110 - NATIONAL SECURITY 336611 - SHIP BUILDING AND REPAIRING US Navy Current Operator: US Navy Waste codes generated (per most recent Biennial Report): D-Codes: D001 D002 D003 D004 D005 D006 D007 D008 D009 D010 D011 D018 D019 D021 D022 D023 D025 D026 D027 D035 D039 D040 D043 F-Codes: F001 F002 F003 F005 P-Codes: P030 P042 P081 U-Codes: U002 U031 U044 U072 U075 U080 State: CR01 CR02 CR04 CR05 Page 4 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 NOTIFICATION IN RCRAInfo: TSDF LQG SQG VSQG Universal Waste Handler: Large Quantity Handler Burner/Blender Transporter Receiving waste from off-site (if so, describe): Generator of State Waste Non-Notifier Other: Facility Operating Status if different from above: N/A Enforcement History: Date 28-Sep-15 12-Mar-14 13-Dec-10 10-Mar-08 13-Oct-05 12-Apr-94 2-Oct-92 Issuing Agency State EPA State EPA State State State Type Field Notice of Violation Written Informal Written Informal Final 3008(A) Compliance Order Written Informal Civil Judicial Action for Imminent and Substantial Endangerment Initial Civil Judicial Action for Compliance and/or Monetary Penalty Violation(s) Generators must determine if their solid waste is a hazardous waste One year accumulation period for SQH HW Generators: Pre-Transport Requirements HW generators: General HW Generators: Pre-Transport Requirements x 6 HW generators: General x 1 Permit Conditions x 4 HW Generators: Pre-Transport Requirements x 6 HW generators: General x 1 Permit Conditions x 4 Universal Waste: General x 1 HW TSD: Closure/Post-Closure x 1 72 Violations Manifests, Recordkeeping and Reporting HW TSD: General x 2 HW TSD: Closure/Post-Closure HW TSD: Financial Requirements HW TSD Contingency Plan and Emergency Procedures Page 5 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 III. IN-BRIEF Credentials Presented: Yes No Attendees (names/titles): EPA: James Carew, Life Scientist Drew Meyer, Environmental Scientist US Navy Brian Hendrickson, Hazardous Waste Branch Manager; David Carter, Lead Environmental Protection Specialist Number of Employees: Size of Facility: Length of Facility at Location: Operating Hours: Number of Shifts: Primary Emergency Coordinator: Alternate Emergency Coordinator: Type of Operation: 5 employees in Hazardous Waste Branch Subase personnel exceeds 9,000 687 Acres 150+ years 24/7 Hazardous Waste Branch has multiple shifts, beginning at 6am Not listed in Hazardous Waste Contingency Plan Not listed in Hazardous Waste Contingency Plan Military Installation Facility Description (principal business, building and property layout, history of company, etc.): The US Navy has continuously owned and operated what is now the Naval Submarine Base New London ("facility" or "Subase") since approximately 1868. The facility is located on the east side of the Thames River, approximately 5 miles north of Long Island Sound. Mr. Brian Hendrickson stated Subase primarily serves as a training base for future submariners. There are also several submarines and crews homeported at the facility, along with various support services for the boats and the military personnel. As identified from the Subase website, included on the base are retail stores, office buildings, classrooms, and recreational facilities. Some military personnel reside in barracks within the footprint of the base, while other member and family housing is located outside the gated base. A publicly accessible museum operated by the US Navy is located outside of the secured facility perimeter. Medical, dental, and veterinary clinics are also operated on the base. Page 6 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Many different buildings are found throughout the base, of which Mr. Hendrickson stated approximately 38 buildings are related to the Hazardous Waste (HW) program. The facility operates one Treatment, Storage and Disposal Facility (TSDF), 13 Hazardous Waste Storage Areas (HWSA) and 62 Satellite Accumulation Areas (SAA). Process Description: Three processes for treatment of HW are conducted at the TSDF, located in Building 562. 1. Oil Filter Crushing - Used oil filters are crushed. Liquid waste is stored in a 5-gallon container and crushed filters stored in a 55-gallon container. 2. Mercuric Nitrate Reclamation - Waste Mercuric Nitrate solution passes by tubing through 3 filters and into a 5-gallon waste container. All filters are disposed of as nonhazardous waste. The liquid waste is disposed of as state regulated waste. 3. Aerosol Can Puncturing Types of Waste Handled: Ignitable (D001) Corrosive (D002) Reactive (D003) TCLP (D004 - D043) Universal Wastes (Types: Other (specify): F or K listed wastes P or U listed wastes Precious Metals Hazardous Scrap Metals Batteries, Lamps, E-Waste) Used Oil State Regulated Wastes Unknown Wastes Handling/Management Methods: Containers Wastewater Treatment ("WWTU") Drip pads HWSA (s) Other Tanks - aboveground Tanks - underground Containment building SAA(s) Comments: IV. PHYSICAL INSPECTION Areas inspected (descriptions and locations): TSDF - Located at building 562. The building contained a staging area, process room, 9 bays with roll up doors and blind sumps. Each bay was designated for a particular type of waste: Acid; Reactive; Oxidizer; Ignitable; Universal; Alkaline; two Toxic; and state regulated waste. The Process/Work Room was the location in which treatment of hazardous waste occurs (oil filter crushing, mercuric nitrate reclamation, and aerosol can puncturing). Warning signs were posted throughout the TSDF and emergency pull stations were located in accessible areas. A fire Page 7 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 suppression system was installed, along with an emergency eye wash station. Evacuation routes were posted on the wall of the staging area. Posting with emergency contacts was not observed. (b) (3) (B), (b) (7)(E), (b) (7)(F) Page 8 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 designated by the facility using a letter and number code. The 90-Day HWSAs were identified using "A", while SAAs were identified with an "S". Temporary HWSAs or SAAs were identified with a "T". The facility maintains a binder in each HWSA and SAA with training certificates of the personnel responsible for management of the area, weekly inspection logs for the area, and a copy of a training presentation for use as a reference. A17 90-Day HWSA, Clinic Pharmacy. A metal container located behind the Subase Clinic and served as the HWSA to which clinic and dental office wastes were stored. At the time of the inspection there was one container of Bulk Chemotherapy Drugs (UN 3248) in the container. SAA S133 Medical Laboratory was located in Building 449. The SAA consisted of one small glass in secondary containment. SAAs S109 and S110 Dental Treatment Rooms were located in Dental Clinic Building 575. The SAAs consisted of plastic containers of approximately 3-gallons in secondary containment stored under a cabinet. S109 and S110 were in separate, adjacent dental treatment rooms. SAA S136 Dental Laboratory. Located in the Dental Clinic Building 575 on the lower floor, the SAA consisted of one 20-gallon container of isopropyl waste contaminated with resin identified as a State Regulated Waste. A40 HWSA was located in Public Works Building 451 ("The Shops"). The HWSA contained two containers of state regulated waste oil, five containers of universal waste. Waste oil had secondary containment, spill control materials was available in the space, warning signs identifying the area as a hazardous waste area were posted. A13 HWSA "Port Ops" was located in Building 1. The HWSA was located inside the building near the loading dock. A grated, blind sump was observed on the floor of the space. One 5-gallon container labeled as "Gasoline/Fuel Filters (Benzene, Toxic)" was observed on top of a 20-gallon container marked of state regulated waste "Used Oil (Filters) for Recycling (Hydraulic Oil/Lube Oil, Motor Oil)", both containers were on a containment pallet. In the corner of the space was a 55-gallon container marked as "Used Oil for Recycling (Hydraulic Oil/Lube Oil, Motor Oil)" (see Photographs 20 in Attachment 2). Above the container were two sings reading "Used Oil" and "Waste Antifreeze". Below each sign, piping and valve connected to a hose were present (see Photographs 20, 22, 25 in Attachment 2). Brian Hendrickson stated the oil and antifreeze flowed through the piping and hose, into the 55-gallon container. The Antifreeze valve appeared to be open and both bungs of the 55-gallon container were open (see Photographs 20, 22-3, 2526 in Attachment 2). The end of the used oil hose was wrapped in oil sorbent material and lying next to the container. The end of the hose marked "Waste Antifreeze" was inserted into the larger open bung of the 55-gallon container marked as "Used Oil for Recycling (Hydraulic Oil/Lube Oil, Motor Oil)" (see Photographs 20, 22-23, 25, 26 in Attachment 2). S127 SAA "Carpenter's Shop" in Building 17. Enclosed by chain link fencing, the SAA contained two containers of used oil and water on secondary containment pallets. Immediately adjacent to SAA S127 in the "Carpenter's Shop" in Building 17 was an area identified as the Nuclear Radiological Maintenance Department (NRMD). In the NRMD area, Page 9 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Inspector Meyer observed two large, plastic containers with the words "Waste Lead" on the lid, (see Photographs 27-28 in Attachment 2). Inspector Meyer asked about the box and contents, the inspection team was escorted to the NRMD area. Contractors on site stated the contents were "temporary lead shielding" that had been damaged. The contractors described the temporary lead shielding as pieces of lead, covered in a thick, plastic fabric covering. Once damaged, typically meaning the fabric has ripped, the shielding is placed in the boxes. A contractor with Electric Boat, Andrew Pigg, stated the damaged shielding was transported to a facility on the Subase, where the lead is separated from the fabric, and the lead recycled. Additionally, a rusted cylinder was observed next to the loading bay door. The cylinder was rusted, unsecured, and contained a partial US DOT Division 2.2 Non-Flammable Gas label. When asked, facility personnel stated that were not sure if the cylinder was a waste or why it was there (see Photograph 31). TSPR "Spruce Barge" SAA was located in Building 38. Two containers of state regulated waste. Containers contain marks and labels. A02 "R-6 Carpenter Shop" HWSA was located in Building 38. The HWSA had four 55-gallon containers of state regulated adhesives, blue, caulk waste (state waste code CR05). Accumulation start date not included on hazardous waste label on any of the four containers. S03 "MIRCS Lab" SAA in Building 40. No waste was observed at the time of the inspection. S42 "Inside Machine Shop" in Building 40 contained one approximately 35-gallon container of state regulated used oil on a spill pallet. S92 "NRMD Supply" SAA in Building 88. No waste was observed at the time of the inspection. A04 "Outside Machine Shop" near Building 88. No waste was observed at the time of the inspection. S27 "MSRA" SAA was located in Building 153. One 5-gallon container of solder material, two 1-gallon containers of state regulated waste. S22 "Mast/Periscope Repair" SAA was located in Building 157. Three 55-gallon containers of state regulated oily waste was observed. Containers were stored on containment pallets, all containers closed at the time of the inspection. S77 "Vulcanizing Shop" SAA was located in Building 456. One 55-gallon container of acetone wipes with no free liquids was observed. S47 SAA near paint booth was located in Building 456. One 55-gallon container of federally regulated, and 3 55-gallon containers of state regulated waste, all stored on spill pallets, was observed. S120 "Rubber and Plastic" SAA was located in Building 456. Three containers of state regulated waste, stored on pill containment pallets were observed. A19 "Electrical Division" HWSA was located outside of Building 456 in a metal storage unit. One container (plastic bag) of federally regulated marine coustifab and debris (Barium/Vinyl Page 10 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Bulked Hydrochloric Acid Lamps (b) (3) Y D002 TSDF BLDG 562 - Acids Bay Y UW TSDF BLDG 26 boxes 562 - Acids Bay (B), (b) (7)(E), (b) TSDF TSDF (7)(F) Hydrazine Y D003, Solution 22% U133 (Reactive) Waste Y D003, Containing Nitro P081 (Reactive) Lithium Y UW Batteries Flammable Waste Liquid (Alcohols) Y D001 Flammable Waste Liquid Y D001 Flammable Waste Paint liquid with Isocyanates Flammable Waste, Liquid (Alcohol) Y D001 Y D001 TSDF BLDG 562 - Reactives Bay TSDF BLDG 562 - Reactives Bay TSDF BLDG 562 - Reactives Bay TSDF BLDG 562 Flammables Bay TSDF BLDG 562 Flammables Bay TSDF BLDG 562 Flammables Bay TSDF BLDG 562 Flammables Bay Flammable Locker Flammable Locker Flammable Locker 1 of 16 drums on 4 pallets, no spacing between pallets or wall 1 of 16 drums on 4 pallets, no spacing between pallets or wall. Incineration hold. TSDF TSDF TSDF TSDF TSDF TSDF TSDF Page 12 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Flammable Liquid Waste Paint Liquid Y D001 Bulked D001 Y D001 Medical & Dental Waste (Flammable) Spent Slide Y D001, Stainer from F003 Manual Process (Flammable/Met hanol) Dental Amalgam Y D009 for Recycling (Mercury) Toxic Used Oil Y CR02 (Filters) for Recycling (Hydraulic Oil / Lube Oil / Motor Oil) Gasoline / Fuel Y D018 Filters (Benzene) Toxic Marine Y D005, Coustifab & D043 Debris (Barium / Vinyl Chloride) Toxic Mil Oil-2431A Y D001 Formula 184 Type 1 TPA (Flammable) Soldering Y D008, Material (Lead D016 & Silver) Toxic Plug Shooting Y F003 Debris (Acetone) Paint & Thinner Y D001, Debris F003 (Flammable, In- Butyl Alcohol) Waste Adhesive Y CR05 Debris TSDF BLDG 562 Flammables Bay A-17 BLDG B449 S-133 Medical Laboratory S-109 & S110 Dental Treatment Rooms A-13 Port Services (Port Ops) State Regulated Waste A-13 Port Services (Port Ops) A-02 R-6 Carpenter Shop TSPR Spruce Barge S-27 BLDG 153 S-77 BLDG 456 S-47 BLDG 456 S-120 BLDG 456 TSDF HWSA SAA SAA HWSA SAA HWSA SAA SAA SAA SAA SAA Page 13 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Adhesive & Debris (MEK) Leather Gloves (EB Workers) (Chromium) Toxic Isopropyl Alcohol / Mineral Spirits Lamps Y D035 Y D007 Y D001 Y UW Gasoline Spill Debris (Benzene) Toxic High Pressure Cylinder Y D018 N S-45 BLDG 478 S-45 BLDG 478 SAA SAA A-44 BLDG 174 S-129 NEX Main Store BLDG 484 S-72 NEX Gas Station BLDG 428 S-127 Temp Boat Services BLDG 17 HWSA Box open, no label, two lamps inside. Fixed while on site. SAA SAA Rusted cylinder stored near loading bay door, partial DOT 2.2 NonFlammable gas label Not in TSDF, HWSA or SAA HAZARDOUS WASTE DETERMINATIONS Requirements Determination conducted for all waste streams, by what method Determination updated, as needed (documentation on-site) Comments: Observations (Yes/NO/NA-Explain if needed) Yes. Generator knowledge and laboratory analysis. Yes. IGNITABLES/REACTIVES/INCOMPATIBLES Requirements Ignitable & reactive wastes separated from sources of ignition or reaction No smoking signs (for ignitable & reactive wastes) Separation of all incompatibles (either incompatible wastes or wastes with incompatible containers) Storage > 50 feet from property line Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Page 14 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Comments: PREPAREDNESS & PREVENTION Requirements: Wastes handled in a manner to minimize the potential for a fire, explosion or a release Arrangements with local authorities Immediate accessible to internal communications/alarm systems Telephone/hand-held two-way radio Emergency equipment (fire extinguishers, spill control decontamination equipment) Equipment maintenance Access to emergency equipment Adequate aisle space (each area) Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Yes Yes No. In the flammables bay of the TSDF, 16 steel 55-gallon containers on four pallets, and four cubic-yard containers were stored with no spacing between pallets. Adequate source of water in the event of a fire (federal regulations) Comments: Two 330-gallon and one 275-gallon container were stored in the "Reactives" bay with no spacing between containers. Yes PRE-TRANSPORT REQUIREMENTS Requirements: Packaging Labeling (if applicable, DOT hazard class) Marking (words "Hazardous Waste", generator information if being shipped) Contents described Proper DOT shipping name Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes SATELLITE ACCUMULATION Page 15 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Requirements: Approximate number of satellite accumulation areas Appropriate amount of waste storage in SAA Containers labeled and marked with contents described SAA at or near point of generation Containers closed when not actively adding or removing waste Condition of containers Impermeable base Secondary Containment Spill Control material Comments: Observations (Yes/No/NA-Explain if Needed) 62 Yes No. UW lamp container in NEX Main Store SAA S-129 in BLDG 484 contained two lamps. Container was not labeled. See Photographs 37 & 38 in Attachment 2 Yes No. UW lamp container in NEX Main Store SAA S-129 in BLDG 484 contained two lamps. Container was open. See Photographs 37 & 38 in Attachment 2 Yes Yes Yes Yes CONTAINER STORAGE - HWSA Requirements: Number of container storage areas Location(s) Containers marked and contents described Containers marked with accumulation start date Approximate number & sizes of containers: Description: Floor drains/sumps Containers closed when not actively adding or removing waste Condition of containers (leaks, ruptures, dents, corrosion, heat, pressure) Impermeable base Secondary Containment Incompatibles separated by e.g., dike/wall Storage less than 90 days or 180 days for SQG (hazardous waste) Spill Control material Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Yes. Blind sumps/drains. Yes. Yes Yes Yes Yes Yes Yes Container marked as "Used Oil", a state regulated waste, in A-13 HWSA in Port Services BLDG 1 had a hose in one of the Page 16 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 two open bung holes. The hose was connected to the wall, below a sign reading "Waste Antifreeze". The valve at the wall hose connection appeared to be open. The end of the hose was in was container labeled as a State-Regulated Waste, waste code CR02. CR02 is defined as "oil or petroleum waste" in the facility's state issued RCRA Part B Renewal Permit (Permit). Antifreeze is listed as CR04 in the Permit. See Photographs 20, 22-23, 25, 26 in Attachment 2 WASTE TANKS No hazardous waste tanks were on site at the time of the inspection. HAZARDOUS WASTE MANAGEMENT IN OTHER TYPE(S) OF UNITS No other types of units were on site at the time of the inspection. USED OIL Requirements: Does the facility generate used oil Is the generator's used oil mixed with other waste(s) What type of waste(s) is used oil mixed with Listed Characteristic Non-hazardous waste If mixture is with characteristic hazardous waste, is the combined waste tested for characteristics Testing for rebuttable presumption Total halogen content determination Total halogen content determined by testing or generator knowledge Are the total halogens less than 1,000 ppm or greater than 1,000 ppm F-listed halogen constituents above 100 ppm Used oil managed according to applicable standards Is used oil accumulated on-site in: Observations (Yes/No/NA-Explain if Needed) Yes N/A N/A N/A N/A N/A N/A N/A N/A N/A Page 17 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015  Container(s) Aboveground tank(s) Underground tank(s) Describe type, method and condition Comments: Steel drums in good condition INSPECTION SCHEDULE AND LOG Requirements: Does the facility claim inspections are conducted (tank and/or container inspections) Written inspection schedule Inspection log (adequacy of contents: date, time, items inspected, corrective actions, identity of inspector, signatures, etc.) Documentation Appropriate tank inspections, including containment, level detection, ancillary equipment Appropriate treatment equipment inspections All loading/unloading areas subject to spills (when in use) All hazardous waste storage areas (satellite and < 90 day where applicable), at all required frequencies All Safety and emergency equipment (monthly) where necessary Tanks cathodic protection (within six months, then yearly) where necessary Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes N/A Yes Yes Yes Yes N/A Inspection logs maintained at each TSDF, HWSA, and SAA in a binder. CONTINGENCY PLAN Requirements: Plan on-site Date of plan Emergency Coordinator(s) name, address, home and office phone numbers Observations (Yes/No/NA-Explain if Needed) Yes February 2019 No. Contingency plan states in section 3.0: "A list of all persons qualified to act as Emergency Coordinator is not provided because such a list would change too frequently to be useful. Instead, Emergency Page 18 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Number to call to report emergency (internal) Plan to local authorities with proof of distribution (police, fire, hospital, emergency response teams) Emergency procedures (fire, explosions, releases/spills) Emergency coordinator(s) on-site or within a short driving distance of the company at all times Emergency equipment list location, description, capabilities Evacuation plan (signal, primary and alternate routes) Has the contingency plan been amended All remaining applicable requirements addressed Comments: Coordinators will be contacted through the SUBASENLON Regional Dispatch Center by telephone at (860) 694-3333." See Appendix M-1 Hazardous Waste Contingency Plan, (Section 3.0 plan) of the state issued RCRA Part B Renewal Permit. Yes No. No evidence contingency plan was delivered to local authorities was available. Yes Yes Yes Yes No. Issued Feb 2019 as part of state issued permit. No edits noted since issue date. Yes PERSONNEL TRAINING RECORDS Requirements: All facility personnel that require training identified All facility personnel that require training have been properly trained New employees trained within 6 months and documentation of OST Annual refresher training for all employees requiring training Last annual training date for each employee Written description of training course Adequate training for all employees Job title, job description, name of employee, and description of required training Job duties related to hazardous waste Records maintained on-site until closure or Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 19 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 three years for former employees Comments: AIR EMISSIONS - SUBPART BB Not applicable AIR EMISSIONS - SUBPART CC Not applicable Tanks: Not applicable MANIFESTS Requirements: Dates/months of shipping records reviewed Manifests maintained for three years Correct EPA ID numbers used All required parts completed Correct shipping names, numbers used Copies distributed correctly Exception reports filed, and available for review Manifests used for all hazardous waste shipments Appropriate copy(ies) on-site: Comments: Observations (Yes/No/NA-Explain if Needed) Even months for Jan 2020- Dec 2022 Yes Yes Yes Yes Yes Yes Yes Yes DATE MANIFEST # WASTE CODES 1/23/2020 000007507TAG D002 1/23/2020 000007508TAG D002, D005, D006, D007, D008 1/29/2020 014293910FLE 1/29/2020 014293913FLE D001, D002, D005, D006, D007, D008, D009, D018, D035, F002, F003, F005, P042, P075, CR02, CR04, CR05 CR04, CR05 QUANTITY FED _KG 24.49 14.97 QUANTITY NONFED _KG 0 0 1,899.32 0 2,679.37 9,145.13 Page 20 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 2/18/2020 3/25/2020 4/28/2020 6/30/2020 6/30/2020 7/7/2020 9/1/2020 9/2/2020 9/9/2020 10/14/2020 10/27/2020 10/28/2020 11/12/2020 12/3/2020 12/9/2020 12/9/2020 12/14/2020 12/30/2020 1/22/2021 1/22/2021 1/27/2021 1/28/2021 2/25/2021 3/16/2021 3/16/2021 3/18/2021 5/3/2021 5/20/2021 014293917FLE 000007512TAG 014293958FLE 014293983FLE 014293986FLE 014303352FLE 014176726FLE 000007515TAG 014294033FLE 000007521TAG 014294066FLE 014294068FLE 000007523TAG 019769755JJK 014294097FLE 014294099FLE 000007524TAG 001949300VES 014294112FLE 014294113FLE 000007526TAG 001949450VES 000007532TAG 014294137FLE 014294138FLE 001931342VES 014294166FLE 015442733FLE D001, D002, D003, D005, D006, D007, D008, D011, D035, CR02, CR04 D008, D009 D001, D002, D005, D006, D007, D008, D009, D010, D011, D018, F002, F003, F005, P081, U002, U154, CR02, CR04, CR05 D008 D001, D002, D003, D005, D006, D007, D008, D011, D035, F003, F005, P001, P075 D008 D001, CR05 D002, D008 D001, D002, D005, D006, D007, D008, D009, D010, D011, D035, F003, F005, CR02, CR04, CR05 D005, D006, D007, D008, CR01 D001, D002, D005, D006, D007, D008, D009, D010, D011, D018, F002, F003, F005 D003 D005, D006, D007, D008 D007 D001, CR02, CR04 D003, D022, P042, U044, U133 D005, D006, D007, D008, CR01 CR04, MA99 D001, D002, D011, CR04 D001, D002, D005, D008, D009, D018, F002, F003, F005, P001, P075, CR02, CR04, CR05 D008 CR04, MA99 D005, D006, D007, D008 D008, U188, CR02, CR04, CR05 D001, D002, D004, D005, D007, D008, D009, D010, D011, D018, D035, U002, CR02, CR04 CR04, MA99 D008 D005, D006, D007, D008, D009 678.91 0.45 2,063.95 284.81 1,658.05 1,814.06 45.35 37.19 1,632.65 5 2,826.31 0.91 59.41 19,047.63 456.69 18.59 24.34 0 26.76 2,335.15 0.91 0 4.99 87.07 1,280.27 0 10,366.9 15.87 4,472.11 0 1,172.34 0 10,337.87 0 0 0 3,843.09 0 0 0 0 0 1,030.39 0 0 907.03 0 6,119.09 0 907.03 0 11,895.84 852.61 263.04 0 0 Page 21 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 5/21/2021 014294172FLE 6/22/2021 7/7/2021 7/7/2021 015306809FLE 014294217FLE 014294218FLE 7/14/2021 014294219FLE 7/21/2021 015442786FLE 7/26/2021 014294221FLE 8/19/2021 015679013FLE 8/31/2021 014294241FLE 9/15/2021 015442783FLE 10/1/2021 014294254FLE 10/13/2021 014294256FLE 11/9/2021 014294269FLE 11/9/2021 014294270FLE 12/1/2021 1/4/2022 1/19/2022 2/23/2022 015442778FLE 014294286FLE 015442776FLE 014294303FLE 2/23/2022 014294304FLE 3/21/2022 4/8/2022 4/8/2022 4/20/2022 016480751FLE 017949494JJK 017949495JJK 015442765FLE 4/26/2022 024210506JJK 4/26/2022 024210509JJK 4/26/2022 024210510JJK 4/26/2022 024210515JJK D001, D002, D003, D008, D009, D011, D018, D021, D035, D039, F002, F003, F005, P081, U019, U154, CR02 CR04, R015 D008, CR02, CR04, CR05 D009 D005, D006, D007, D008, OUTS409H D005, D006, D007, D008 D001, D002, D005, D006, D007, D008, D010, D011, D018, F003, F005, CR04, CR05 D008 D001, D005, D006, D007, D008, D009, D011, CR02, CR04, CR05 D005, D006, D007, D008 D008 D001, D008, F002, F003, F005, CR02, CR04, CR05 D001, D002, D005, D006, D007, D008, D009, D010, D011, D018, F002, F003, F005, CR02, CR04, CR05 D005, D006, D007, D008, OUTS409H D002 D002, D007, D008, D010 D005, D006, D007, D008 D008 D001, D002, D008, D009, D018, CR02, CR04, CR05 CR05, VT21, VT22, VT99 CR04, R015 CR04, R015 D002, D007 D001, D002, D007, D010, D011, P042, U002, U154 D001, D002, D007, D010, D011 D001, D003, D011, U133, U154, U220 U210, OUTS001H 1,683.9 0 67.12 4.54 9 33.56 961.45 181.41 112.93 21.77 7,619.05 220.86 1,722 32 21.32 57.6 11.34 1,282.54 295.24 0 0 0 8.16 80.73 66.21 45.35 3.63 951.93 416.07 3,260.12 0 0 0 2,863.04 0 8,443.61 0 0 5,703.67 7,005.52 0 0 5,714.81 0 0 5,202.27 434.79 136.05 136.05 0 0 0 0 0 Page 22 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 4/26/2022 024210507JJK 4/26/2022 024210513JJK D001, D002, D005, D007, D011, D035, D039, F003 D001, D002, D003, D005 4/26/2022 024210514JJK D001, D005, D007, D008, D011, D035, D043, F003, F005 4/26/2022 024210508JJK 5/12/2022 5/12/2022 5/12/2022 5/12/2022 024210519JJK 024210520JJK 024210522JJK 024210523JJK 5/12/2022 024210521JJK 5/26/2022 5/26/2022 6/1/2022 6/14/2022 7/27/2022 9/2/2022 024210541JJK 016188239FLE 015442762FLE 023099348JJK 015442759FLE 024210615JJK 9/20/2022 024210618JJK 9/20/2022 024210619JJK 9/21/2022 015442738FLE 9/21/2022 015442741FLE 9/23/2022 017941158FLE 10/18/2022 016595408FLE 11/4/2022 024210648JJK 11/21/2022 12/6/2022 12/7/2022 12/7/2022 12/19/2022 017769102FLE 015442742FLE 024210687JJK 024210688JJK 016593854FLE D001, D002, D005, D008, D011, D035, P001, P075 F002 D002, D009, D011 D001, D002, D009 CR02, CR04, CR05 D001, D009, D010, D011, D024, P081, CR04 D001, D002, D003, D006, D009 CR05, R015 D005, D006, D007, D008 CR02, MA98 D002, D005, D006, D007, D008 D002, P001, P075 D001, D005, D006, D007, D008, D009, D010, D011, CR04 D001, D002, D011, D018, D035, F003, F005 CR01 D002, D005, D006, D007, D008, CR01 D008 D006 D001, D006, D007, D009, D011, D035, D039, F003, F005, CR04 D008 D007 D001, F003, F005, CR05 D018, CR04, CR05 D008 2,360.09 1,018.14 2,753.29 1,118.37 5.9 4.54 10.88 0 8.62 2.72 0 19.5 0 15.42 3.63 761.91 1,542.86 0 14.06 1,687.08 43.08 1,135.6 73.02 0.45 306.58 512.93 6,820.87 0 277.55 0 0 0 0 1,217.69 3,647.43 11.79 0 544.22 0 18,912.22 0 0 10,242.18 434.47 3.17 0 0 0 3,568.26 0 0 19.05 802.72 0 LAND DISPOSAL RESTRICTIONS Requirements: Generator has determined whether the waste meets treatment standard(s) Observations (Yes/No/NA-Explain if Needed) Yes Page 23 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 If the waste or contaminated soil does not Yes meet the treatment standard(s), the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility or the generator has sent individual notification(s) for each shipment of waste If the waste or contaminated soil meets the Yes treatment standard(s) at the original point of generation, the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility The generator has identified all appropriate Yes waste codes and/or underlying hazardous constituents (UHCs) on each shipment The generator retained on-site a copy of each Yes LDR documentation for 3 years Comments: IMPORT/EXPORT ACTIVITIES Not applicable ANNUAL/BIENNIAL REPORT Requirements: The company has completed an annual or biennial report, when/if it is required Comments: Observations (Yes/No/NA-Explain if Needed) Yes UNIVERSAL WASTE Requirements: Does the company/facility handle universal wastes What universal wastes are handled/generated by the facility Does the company/facility qualify as an LQH or SQH of universal waste Does the current handling of universal waste prevent breakage, leakage, spillage or damage that could cause leakage Observations (Yes/No/NA-Explain if Needed) Yes Lamps, Batteries, E-waste LQH as listed in Biennial Report Yes Page 24 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Are the containers of universal waste structurally sound and compatible with the contents Do the universal waste containers carry appropriate markings/labeling Does universal waste meet the requirements for accumulation start date Does the generator comply with the less than one year accumulation time limit Is the universal waste item or container dated from the earliest receipt of the item or when first placed in the container Does the company/facility keep appropriate manifests or shipping documents of universal wastes either received at or shipped from the facility to a destination facility Are records kept for at least three years from date of receipt to or transfer from the facility Comments: Yes No. Lamp container in NEX Main Exchange SAA S-129 in BLDG 484 contained two lamps and was not marked at the time of the inspection. Fixed while inspection team was on site. Yes Yes No. Lamp container in NEX Main Exchange SAA S-129 in BLDG 484 contained two lamps and was not dated at the time of the inspection. Fixed while inspection team was on site. Yes Yes OUT-BRIEF List Attendees (names/titles): EPA Region 1: James Carew, Life Scientist, RCRA Inspector US Navy: Brian Hendrickson, Hazardous Waste Branch Manager David Carter, Lead Environmental Protection Specialist Michael Brown, Environmental Director Bernadette Reese, Senior RCRA Program Manager, NAVFAC MIDLANT EV12 Summary of outbrief: A virtual out-brief was held on March 13, 2023 using the Microsoft Teams platform with attendees from EPA Region 1 and the US Navy. During the out-brief, Inspector Carew provided a brief summary of the inspection conducted February 22-23, 2023 and the following topics were discussed: 1. Open/unlabeled lamp container at the NEX Main Store SAA 2. Cylinder in NRMD building. 3. Spacing of containers in Acid and Ignitable bays in Building 562. Page 25 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 4. Waste Antifreeze hose in a container labeled as state regulated "Used Oil for Recycling" in in Port Services Building 1. 5. Fabric for Lead Shielding in NRMD building. 6. Emergency Coordinators in Hazardous Waste Contingency Plan. 7. Distribution of the Hazardous Waste Contingency Plan. Outbrief notes: x Mr. Michael Brown stated the cylinder was determined to be in use (not a waste) and has been removed from the location at which it was stored at the time of the inspection. x Mr. Hendrickson stated the fabric and shielding are transported off site intact for recycling. x Mr. Hendrickson stated a new contract was established by DLA that will allow for the transport and disposal of many of the containers currently on "incineration hold". The waste is expected to be picked up and transported within the next few weeks. List of Attachments: ATTACHMENT #1: ATTACHMENT #2: ATTACHMENT #3: ATTACHMENT #4: ATTACHMENT #5 ATTACHMENT #6: CT DEEP Issued Storage Extension for the Temporary Backlog of Containerized Hazardous Waste Needing Incineration Naval Submarine Base New London (SUBASE) Digital Images taken by EPA Region 1 during the inspection Subase HWSA & SAA List Subase TSDF Inventory CT DEEP Issued RCRA Part B Renewal Permit Waste Profiles Page 26 of 26 EPA RCRA Inspection Checklist Version 1a - November 17, 2015